Anti-Corruption Policy

Policy owner: Jarvis Luong

Effective date: 25.01.2025

Policy Statement

Commitment to Integrity

Tekai is dedicated to conducting business with the highest standards of integrity and ethical behavior. We maintain a strict zero-tolerance approach to all forms of corruption, including bribery, fraud, and unethical practices. This policy applies to all employees, officers, directors, contractors, consultants, agents, and any third parties representing Tekai.

Definitions

• Bribery: Offering, giving, receiving, or soliciting anything of value to influence the actions of an individual in a position of power.
• Corruption: Abuse of entrusted power for private gain.
• Facilitation Payments: Minor payments made to expedite routine governmental actions (Note: Tekai prohibits all facilitation payments).
• Gifts and Hospitality: Items, services, or favors given to or received from third parties, which could influence business decisions.

Prohibited Conduct

• Bribery: Employees must not offer, give, solicit, or accept bribes in any form, whether directly or indirectly.
• Kickbacks: Accepting or providing kickbacks in exchange for preferential treatment or business advantages is strictly forbidden.
• Facilitation Payments: Any form of facilitation payments is prohibited, regardless of jurisdiction. Unapproved Gifts and Hospitality: Offering or accepting gifts, hospitality, or other benefits that could influence business decisions is not allowed unless explicitly approved.

Gifts, Hospitality, and Expenses

• Acceptable Gifts: Modest and infrequent gifts (valued under €50) that are customary in business relationships.
• Unacceptable Gifts: Expensive or frequent gifts, or those that could influence business decisions, are prohibited.
• Reporting Requirements: All gifts and hospitality exceeding €50 must be reported to the Compliance Officer for approval.

Third-Party Relationships

Due Diligence and Compliance

• Tekai will conduct basic due diligence on all third-party partners, including vendors and service providers, to ensure their adherence to anti-corruption standards.

1. Reporting and Whistleblowing

• Reporting Mechanism: Employees and third parties are encouraged to report any suspected instances of corruption or policy violations through a secure online form: https://docs.google.com/forms/d/e/1FAIpQLSeY99GR1bOIR-ngB8NgWZbyWQ5XAfiLaBf_L37bJiidCuAxOQ/viewform?usp=dialog, or via managers@tekai.fi, or via CIO.
• Protection Against Retaliation: Tekai prohibits retaliation against individuals who report concerns in good faith. Reports will be handled confidentially and investigated promptly.

Responsibilities and Accountability

• All Employees: Must adhere to this policy and avoid any actions that could constitute corruption.
• Managers and Supervisors: Responsible for promoting ethical behavior and ensuring their teams comply with the policy.
• Compliance Officer: Oversees the implementation and enforcement of the Anti-Corruption
• Policy, conducts basic training, and manages reports of misconduct.

Training and Awareness

Basic Training: All employees will receive introductory training on anti-corruption laws, company policies, and ethical business practices during onboarding and annually thereafter. Policy Accessibility: This policy is available on the company intranet and must be reviewed by all employees upon hiring.

Disciplinary Actions

Violations of this Anti-Corruption Policy may result in disciplinary actions, including termination of employment and legal prosecution. Tekai will take all necessary measures to enforce this policy and maintain a corruption-free workplace.

Monitoring and Review

Periodic Review: This policy will be reviewed annually or as necessary to reflect changes in laws and business practices.

Continuous Improvement: Feedback from employees will be considered to improve the effectiveness of this policy.

Contact Information

For questions, reporting concerns, or seeking guidance, please contact:

Compliance Officer: Jarvis Luong (jarvis@tekai.fi)